Modern Slavery Act Statement 2018

This is Utmost Limited’s statement on its approach to modern slavery following the introduction of the UK Modern Slavery Act 2015 (the “Act”).

This statement sets out the steps that have been taken or that have begun to be taken by Utmost Limited during the financial year ended 31 December 2018 to assist in the detection and prevention of modern slavery across its business operations and supply chains.

Who are we?

Utmost Limited is based on the Isle of Man and is a member of the Utmost Group, which has provided life assurance and capital redemption bonds to high net worth clients predominantly located in the United Kingdom through fully regulated partners and intermediaries for the past 25 years. It has over £10bn of assets under administration and strives to offer its clients outstanding levels of service and innovative products.

Our Internal Policies

We have considered our internal policies in respect of measures which could assist in the prevention of modern slavery from taking place in our business dealings.

We follow the principles of good corporate governance and Enterprise Risk Management and do not tolerate any malpractice, whether committed by senior managers, staff, suppliers or contractors acting on our behalf (“our Governance Framework”).

A Code of Conduct (“Code”) is included in our Governance Framework and applies to all directors, officers and employees and requires that they adhere to the Principles of Conduct and Ethics (the “Principles”). The Principles state that staff must act with integrity, objectivity, confidentiality and in a professional manner. Staff are encouraged to report any practices or actions where they believe these to be inappropriate or inconsistent with the Code or that may compromise the ethical standards or integrity of the organisation.

The procedure for reporting inappropriate, unethical or inconsistent practices with that of the Code is set out in our Whistleblowing Policy. This policy provides for a member of staff to report any improper conduct or unethical behaviour in the first instance to their manager, senior manager or the Chief Executive Officer directly if they wish.

Where they feel that they cannot raise a concern with these individuals, they may make contact on a confidential basis with the Chairman of the Audit Committee, after which their report will be investigated and considered by all of the Non-Executive Directors. At all times during any investigation the Whistleblower’s identity will be kept confidential. Staff members are reminded of their right to raise concerns under the Whistleblowing Policy, and to consult with associated guidance, by the Chairman of the Audit Committee annually.

Our Suppliers

Utmost Limited accepts a range of goods and services from suppliers located across the globe, although the majority of these have their operations locally in the Isle of Man or the United Kingdom. Goods and services utilised by us consist of catering, cleaning, office furniture and stationery, Information Technology, property maintenance and utilities.

We have assessed our suppliers using a risk based approach and there are currently none which are deemed to be higher risk under the Act. This assessment is based on their area of geographical operation, the type of industry in which they operate and their publicly disclosed policies on slavery and human rights. Where a supplier is identified, contact is made with them to let them know that it is expected that they comply with the terms of the Act.

Future actions

Utmost Limited expects high ethical standards and legal compliance from the suppliers that it deals with.

For those suppliers that are identified as higher risk we will introduce contractual terms which seek to ensure that they are in compliance with the Act. We will implement procedures where we ask identified suppliers to report any possible breaches of the Act to us for referral to our Management Committee for consideration.

Approved by the Board of Directors of Utmost Limited

26 March 2019